SecProbe.io

CORRESP
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    a5556808.htm

    November
      29, 2007

    Via
      Electronic Submission and Overnight Courier

    United
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    100
      F
      Street N.E.

    Washington,
      D.C.  20549

              Attention:

              Kate
                Tillan, Assistant Chief Accountant

              RE:

              Anika
                Therapeutics, Inc.

              Form
                10-K for the fiscal year ended December 31,
                2006

              Filed
                March 13, 2007

              Form
                10-Q for the quarter ended September 30, 2007

              File
                No. 001-14027

    Dear
      Ms.
      Tillan:

    This
      letter is being furnished in response to comments of the staff (the “Staff”) of
      the Securities and Exchange Commission (the “Commission”) as set forth in your
      letter dated November 19, 2007 (the “Comment Letter”) to Kevin Quinlan, Chief
      Financial Officer Anika Therapeutics, Inc. (“Anika” or the “Company”), with
      respect to the Company’s Annual Report on Form 10-K for the fiscal year ended
      December 31, 2006 and Quarterly Report on Form 10-Q for the quarter ended
      September 30, 2007.  The responses set forth below have been organized
      in the same manner in which the Commission’s comments and headings were
      organized in the Comment Letter.

    Form
      10-K for the Fiscal Year Ended December 31, 2006

    Controls
      and Procedures, page 66

              1.

              We
                note your disclosure that your “chief executive officer and principal
                financial officer have concluded that [y]our disclosure controls
                and
                procedures are reasonably effective to ensure that
                material information relating to [you] required to be disclosed by
                [you]
                in reports [you] file or submit under the Exchange Act is recorded,
                processed, summarized and reported within the time periods specified
                in
                the Securities and Exchange Commission rules and forms.” [emphasis
                added]  It does not appear that your certifying officers have
                reached a conclusion that your disclosure controls and procedures
                are
                effective.  Please revise future filings to address your
                officers’ conclusions regarding the effectiveness of your disclosure
                controls and procedures.  In addition, please note that the
                definition of disclosure controls and procedures is included in Rule
                13a-15(e) of the Exchange Act.  However, if you wish to include
                the definition following your conclusion, please revise the disclosure
                in
                future filings so that the language that appears after the word
                “effective” is substantially similar in all material respects to the
                language that appears in the entire two-sentence definition of “disclosure
                controls and procedures” set forth in Rule
                13a-15(e).

      Securities
        and Exchange Commission

      November
        29, 2007

      Page
2

    The
      Company acknowledges the comments of the Staff, and in the Company’s future
      filings, commencing with the Company’s Annual Report on Form 10-K for the fiscal
      year ending December 31, 2007, the Company will more clearly state our officers’
conclusions regarding the effectiveness of the Company’s disclosure controls and
      procedures and otherwise implement the disclosure recommendations of the
      Staff.

    Form
      10-Q for the Quarterly Period Ended September 30, 2007

    Controls
      and Procedures, page 24

              2.

              We
                note your statement that “the Company’s disclosure controls and procedures
                were effective at the reasonable assurance level.”  Please
                revise future filings to state clearly, if true, that your disclosure
                controls and procedures are designed to provide reasonable assurance
                of
                achieving their objectives and that your principal executive officer
                and
                principal financial officer concluded that your disclosure controls
                and
                procedures are effective at that reasonable assurance level.  In
                the alternative, remove the reference to the level of assurance of
                your
                disclosure controls and procedures.  Please refer to Section
                IIF.4 of Management’s Reports on Internal Control Over Financial Reporting
                and Certification of Disclosure in Exchange Act Periodic Reports,
                SEC
                Release No. 33-8238, available on our website at
                http://www.sec.gov/rules/final/33-8238.htm.

    The
      Company acknowledges the comments of the Staff, and in the Company’s future
      filings, commencing with the Company’s Quarterly Report on Form 10-Q for the
      quarter ending March 31, 2008, the Company will state clearly, if true, that
      our
      disclosure controls and procedures were designed to provide reasonable assurance
      of achieving their objectives and that our principal executive officer and
      principal financial officer concluded that our disclosure controls and
      procedures were effective at that reasonable assurance level.

    The
      Company acknowledges that:

              ·

              the
                Company is responsible for the adequacy and accuracy of the disclosure
                in
                the filing;

              ·

              Staff
                comments or changes to disclosure in response to Staff comments do
                not
                foreclose the Commission from taking any action with respect to the
                filing; and

              ·

              the
                Company may not assert staff comments as a defense in any proceeding
                initiated by the Commission or any person under the federal securities
                laws of the United States.

      Securities
        and Exchange Commission

      November
        29, 2007

      Page
3

    If
      you
      have any questions with regard to the Company’s responses or would like to
      discuss any of the matters covered in this letter, please contact the
      undersigned at (781) 457-9000.

    Sincerely,

                /s/
                  Kevin Quinlan

                Kevin
                  Quinlan

                Chief
                  Financial Officer